John Michael and Janice Hill Brannon - Page 4




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          above within the boundaries of their charge, and only as long as            
          they are licensed by the Church to do so.                                   
               Petitioner's annual earnings from performing as a local                
          pastor the services described above exceeded $400 in 1983 and               
          1984.                                                                       
               The application for exemption from self-employment tax                 
          contemplated by section 1402(e) is embodied in Form 4361,                   
          "Application for Exemption from Self-Employment Tax for Use by              
          Ministers, Members of Religious Orders, and Christian Science               
          Practitioners".  In addition to other information, an applicant             
          for exemption must report on that form:  (1) The date that the              
          applicant was "ordained, licensed, etc." (line 3); and (2) the              
          first 2 years after the date listed on line 3 that the applicant            
          had "net self-employment earnings of $400 or more, any part of              
          which came from services as a: minister, priest, rabbi, etc."               
          (line 5).                                                                   
               On April 17, 1989, petitioner filed a Form 4361.  On that              
          form petitioner indicated that the date he was "ordained,                   
          licensed, etc." was May 25, 1987 (the date that he was ordained a           
          deacon).  He reported that 1988 and 1989 were the first 2 years             
          after the date of his ordination in which he had "net self-                 
          employment earnings of $400 or more, any part of which came from            
          services as a: minister, priest, rabbi, etc."  Relying upon the             
          information reported on the form, on April 9, 1990, respondent              





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